Samantha is a UK resident remittance basis user. On 1 March 2008 she agreed a mortgage facility with an overseas bank of £1,000,000 to use to purchase a UK property. Samantha intends to pay interest on the loan out of her ‘relevant foreign income’.

On 10 March, Samantha agreed to purchase a residential property and the bank transferred £750,000 to her Solicitor’s account that was in turn transferred to the person selling the property. Because the money was lent to enable Samantha to acquire an interest in the property (and for no other purpose) the £750,000 is covered by ‘grandfathering’.

On 10 March the bank transferred the remaining £250,000 of the agreed lending facility to Samantha’s bank account in the Isle of Man where it remained until 10 May 2008 when it was remitted to the UK and used to acquire a further interest in the residential property. Because this £250,000 was received in the UK after 6 April 2008 the interest payments that must be made in respect of this ‘additional’ amount of £250,000 are, from 10 May onwards, a taxable remittance of Samantha’s overseas income and gains.